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Construction of Jurisdictional Statutes as Precluding Exercise

28 U.S.C.S. § 1257(a) provides that Congress has vested the authority to review state court judgments only in the United States Supreme Court.  The Rooker-Feldman doctrine interprets 28 U.S.C.S. § 1257 as ordinarily barring direct review in the lower federal courts of a decision reached by the highest state court, for such authority is vested solely in the Supreme Court.[i]

State supreme courts may act in a nonjudicial capacity in promulgating rules regulating the bar.  Therefore, challenges to the constitutionality of state bar rules, do not require a United States district court to review a final state-court judgment in a judicial proceeding.  United States district courts have subject-matter jurisdiction over general challenges to state bar rules, promulgated by state courts in nonjudicial proceedings, which do not require review of a final state-court judgment in a particular case.  However, they do not have jurisdiction over challenges to state-court decisions in particular cases arising out of judicial proceedings even if those challenges allege that the state court’s action was unconstitutional.  Review of such decisions may be had only in the United States Supreme Court.[ii]

If federal district courts are precluded from reviewing the decisions of a state’s highest court, even when those decisions appear to the district court to have been plainly in violation of the Constitution, then federal district courts are also precluded from reviewing decisions of lower state courts, which are subject to correction and modification within the state court system.[iii]


[i] Brown & Root, Inc. v. Breckenridge, 211 F.3d 194 (4th Cir. W. Va. 2000)

[ii] Triffin v. Nix, 1994 U.S. Dist. LEXIS 5407 (E.D. Pa. Apr. 25, 1994)

[iii] Port Authority Police Benevolent Ass’n v. Port Authority of New York & New Jersey Police Dep’t, 973 F.2d 169 (3d Cir. N.J. 1992)

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